Privacy

PRIVACY POLICY Directive 95/46/CE – “on the protection of individuals with regard to the processing of personal data and on the free movement of such data”. Directive 2002/58/CE – “concerning the processing of personal data and the protection of privacy in the electronic communications sector”. Legislative Decree 30 June 2003, n. 196 – “Personal Data Protection Code”.

THE “DATA CONTROLLER” As a consequence of the visit to this Site, the data referring to identified or identifiable people are subject to be processed. The “Data Controller” of such processing is Spotlight S.r.l. Via Sardegna, 3 – 20098 – S.Giuliano Milanese (MI)

PLACE OF THE PROCESSING OF PERSONAL DATA The treatments related to the web services of this website take place at the service provider appropriately appointed Data Processor and are only handled by technical staff in charge of occasional maintenance operations.

KINDS OF PERSONAL DATA PROCESSED Navigation data The computer-based systems and the software procedures involved in the working of this Web site, in the course of their normal service, come into possession of some personal information, the transmission of which is implied in the use of the protocols of Internet communication. This information is not collected to be associated to any identified people, but, through processes and associations with data owned by third parties, by its own nature might lead to the identification of users. In this category of data are included the IP addresses or the names stored in the domain of the computers used by those who access the Site, the addresses in notation URI (Uniform Resource Identifier) of the required resources, the time of the request, the method used to forward the request to the server, the size of the file received in reply, the digit code showing the state of the reply given by the server (good, error, etc…) and other parameters connected with the operating system and the structure and conditions of the user’s computer. This data is used only to get anonymous statistical information about the use of the Site and to check its correct performance and is deleted immediately after processing. The data might be used to investigate responsibilities, should there be any data processing offences against the Site.

Data voluntary provided by the user The optional, explicit and voluntary forwarding of personal data from the user on contacts or on registration forms present on this Site implies the subsequent acquisition of the data provided by the sender, which is essential to the procession of the required service. Specific, concise information to data subjects will progressively be reported or displayed on the pages of the Site set up for particular services on demand.

VOLUNTARY PROVIDING OF PERSONAL DATA Except for what has been specified for navigation data, the user is free to provide the personal information stated on request forms or indicated during contacts with the Office to further the dispatch of information material or of other communications.

PROCESSING ARRANGEMENTS Personal data is processed with automated instruments only for no longer than is necessary for the purposes for which the data were collected or subsequently processed. Specific security procedures are kept to prevent the risk of their destruction or loss, whether by accident or not, of unauthorized access to the data or of processing operations that are either unlawful or inconsistent with the purposes for which the data have been collected. Spotlight S.r.l.. have adopted all the Minimum Security Measures provided by the law. Spotlight S.r.l.. in accordance with the main international standards, have also taken further security measures to minimize risks regarding to the confidentiality, integrity and availability of the personal data collected and processed.

SHARING, COMMUNICATION AND DISSEMINATION OF DATA The data we collect may be transferred or communicated to other related to Spotlight S.r.l.for activities closely connected and instrumental to the efficiency of the service, such as the management of the data processing system. Apart from said case, data will not be disclosed nor given to anybody unless this is in compliance with contractual and legal obligations or users have given their consent. Therefore, personal information may be transmitted to third parties solely and exclusively if there is an explicit consent to share data with third parties; there is the need to share the information in order to process users’ requirements; this is essential to execute requests from Judicial Authorities or from the Police. No data whatsoever coming from the Web is ever disclosed or circulated.

DATA SUBJECT’S RIGHTS Data subjects have the right, at any time, to obtain confirmation as to whether or not personal data concerning him exist, to know its content and source, to verify its accuracy or to demand its integration, updating or rectification (Art. 7, Legislative Decree 30 June 2003, n. 196). In accordance with said Article, you have the right to ask for the erasure, the anonymization or the blocking of data that have been processed unlawfully, and, furthermore, to object on legitimate grounds, to the processing of personal data, even though they are relevant to the purpose of the collection.

CHANGES TO THE CURRENT PRIVACY POLICY Spotlight S.r.l.check their own privacy and security policy regularly and, if necessary, review it in accordance with the amendments introduced by the law, the organization, or prompted by technological evolution. Any changes to said policy will be posted on this page.

QUERIES, COMPLAINTS AND SUGGESTIONS Whoever might be interested in additional information, or wishes to contribute their own suggestions or might want to send in complaints or concerns about any issues arising in connection with either the privacy policy or the way Spotlight S.r.l. Via Sardegna, 3 – 20098 – S.Giuliano Milanese (MI)